Privacy Policy

1. Purpose and scope

Day Group Inc. (“Day Group”, “we”, “us” or “our”) is a Licensed Insolvency Trustee firm regulated by the Office of the Superintendent of Bankruptcy Canada (“OSB”).

This Privacy Policy explains how we collect, use, disclose, retain and safeguard personal information obtained through daydebt.com, including its enquiry forms, calculators and live chat features, and through communications arising from those services.

We handle personal information in accordance with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and Alberta’s Personal Information Protection Act, where applicable.

If you engage us to provide insolvency services, additional notices, authorizations and statutory requirements may apply. Information associated with a bankruptcy or consumer proposal is also subject to the Bankruptcy and Insolvency Act (“BIA”), the Bankruptcy and Insolvency General Rules, applicable OSB directives and other legal obligations.

This Policy does not limit those obligations or your rights under applicable privacy law.

2. Personal information we collect

Information you provide

Depending on the service you request and the form you complete, we may collect:

• your name, email address and telephone number;
• the approximate amount and types of debt you owe;
• your household size and approximate monthly take-home income;
• whether you have previously filed a bankruptcy or consumer proposal;
• information you provide in messages, enquiries or chat conversations;
• calculator inputs and estimates associated with your enquiry; and
• records of your consent, communication preferences and interactions with us.

Financial information, including information about debt, income and previous insolvency proceedings, may be sensitive personal information.

We limit collection to information reasonably necessary for the identified purpose. You are not required to provide financial information simply to browse our website. You may contact us by telephone to discuss an alternative way of providing information.

Please do not submit your Social Insurance Number, passwords, banking credentials, full payment-card details or full financial account numbers through general website forms or live chat. If additional documents or identifiers are required, we will explain how to provide them appropriately.

Information collected automatically

When you visit our website, we may collect technical and usage information, including:

• your IP address;
• browser and device information;
• pages visited and the date and time of visits;
• referral sources and campaign information; and
• cookie identifiers and interactions with website features.

Some of this information may constitute personal information, particularly when it can be associated with an identifiable individual.

Live chat

Our website uses Tawk.to to support live chat. When you use this feature, Tawk.to processes chat content and associated technical information on our behalf.

Please provide only information reasonably necessary to explain your enquiry. Tawk.to’s own privacy notices describe its handling of information in connection with its services.

3. Purposes for collection and use

We collect and use personal information for the following purposes:

• responding to your enquiry;
• arranging and administering a consultation;
• providing a requested calculator estimate;
• preparing a preliminary assessment of the circumstances you describe;
• communicating with you about your enquiry, appointment or requested services;
• maintaining appropriate enquiry and consent records;
• operating, securing and improving our website;
• measuring website performance, subject to applicable consent requirements;
• sending optional educational or promotional communications where we have the required consent or another lawful basis; and
• meeting legal, regulatory and professional obligations.

We do not sell, rent or trade your personal information or contact details.

Information provided through a form or calculator does not, by itself, constitute a formal insolvency filing, acceptance of an engagement or confirmation that you qualify for a particular debt-relief option.

4. Consent and your choices

We identify the purposes for collecting personal information at or before collection and obtain consent where required by law.

For sensitive financial information, we obtain express consent where required and explain the information we need, how it will be used and any material disclosures.

Submitting an enquiry authorizes us to handle the information for the purposes clearly identified with that enquiry. It does not, by itself, constitute consent to unrelated uses, advertising disclosures or ongoing promotional communications.

Where we request express consent to optional marketing, that choice is presented separately and is not a condition of obtaining a consultation or accessing our services.

You may withdraw consent by contacting our Privacy Officer, subject to legal or contractual restrictions and reasonable notice. We will explain any consequences, including whether withdrawal prevents us from providing a requested service.

Withdrawal of consent does not require us to delete information that we must retain or disclose by law.

We may collect, use or disclose information without consent only where applicable law permits or requires it.

5. Email, text messages and CASL

We distinguish between communications about an enquiry or service you requested and optional promotional communications.

Where Canada’s Anti-Spam Legislation (“CASL”) applies, we send commercial electronic messages only with valid express consent, valid implied consent or an applicable statutory exemption.

We do not treat acceptance of this Privacy Policy as express consent to receive promotional emails or text messages.

Commercial electronic messages subject to CASL’s identification and unsubscribe requirements include:

• identification of Day Group and, where required, any person on whose behalf the message is sent;
• the required mailing address and contact information; and
• a clear, readily accessible and no-cost unsubscribe mechanism.

The unsubscribe mechanism remains valid for at least 60 days after the message is sent. We implement unsubscribe requests without delay and no later than 10 business days after receiving them.

You may also withdraw marketing consent by contacting us directly.

Unsubscribing from marketing does not prevent communications that are required by law or otherwise lawfully sent in connection with requested or ongoing services. We will not use service communications to circumvent an unsubscribe request.

We retain appropriate records to demonstrate the basis on which commercial electronic messages are sent.

6. Disclosure of personal information

We disclose personal information only for identified purposes and where consent or another lawful basis permits the disclosure.

Recipients may include:

Service providers. Providers supporting website hosting, enquiry management, appointment scheduling, email or text delivery, live chat, security and website measurement. We require service providers handling information on our behalf to apply appropriate safeguards and contractual restrictions consistent with their services and applicable law.

Professional advisors. Legal, accounting and other professional advisors where reasonably necessary.

Authorized recipients. A person you have authorized to receive information, subject to appropriate verification.

Legally required or permitted recipients. Regulators, courts, law enforcement or other parties where disclosure is required or permitted by law.

We do not disclose sensitive financial information to advertising platforms merely because you submit an enquiry. Any proposed advertising use or disclosure must be assessed separately for lawful purposes and appropriate consent.

7. Insolvency proceedings and public records

A confidential enquiry or consultation is not itself a public insolvency filing.

If you proceed with a bankruptcy or consumer proposal, we must collect, retain and disclose information required to administer the proceeding under the BIA and related requirements.

Depending on the proceeding, recipients may include the OSB, the official receiver, creditors, courts and other persons entitled to receive the information.

Certain information about bankruptcies and proposals is recorded in the OSB’s public insolvency records and may be accessed through its record-search services. Other documents may be accessible as permitted by applicable law or court procedures.

Before a filing, your trustee will explain the material disclosure requirements and implications of the process.

Privacy requests cannot require us to suppress, alter or destroy records contrary to statutory obligations.

8. Cookies, analytics and advertising technologies

Our website may use cookies and similar technologies for essential functions, preferences, live chat, analytics and, where enabled, advertising measurement.

We use Google Tag Manager to manage website tags. The information collected and the recipients depend on the individual tags configured through it.

Where analytics or advertising tools are enabled, we provide appropriate information about their purposes and obtain consent where required before collecting, using or disclosing personal information.

Because visits to a debt-relief website may reveal or permit inferences about sensitive financial circumstances, advertising tracking requires particular care. We do not treat continued browsing or acceptance of this Policy as blanket consent to sensitive profiling or advertising disclosures.

You may block or delete cookies through your browser settings. Where website privacy controls are available, you may also use them to manage optional technologies.

Blocking certain cookies may affect website functionality. Browser controls and analytics opt-out tools may not prevent all forms of tracking or remove information previously collected.

9. Storage and processing outside Canada

Personal information may be stored or processed in Canada or another country by service providers supporting our operations, including providers with infrastructure in the United States.

Information processed outside Canada may be subject to the laws of that jurisdiction and lawful access by its courts, law enforcement or other public authorities.

Where information is transferred to a service provider, we remain responsible for meeting the obligations applicable to us and use appropriate contractual and other measures to protect the information.

You may contact our Privacy Officer for information about our use of service providers outside Canada.

10. Retention and disposal

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and to meet applicable legal, regulatory and professional obligations.

Retention periods depend on the nature of the information, the status of your enquiry or engagement, consent-record requirements, statutory retention periods and any applicable dispute or legal hold.

Records relating to insolvency proceedings are retained in accordance with the BIA, the Bankruptcy and Insolvency General Rules, applicable OSB directives and other legal requirements.

When information is no longer required, we securely destroy, erase or anonymize it, as appropriate. Copies in backups may remain until those backups are securely overwritten or deleted through the applicable retention cycle.

You may request deletion of information associated with a website enquiry. We will assess the request and explain any lawful reason for retaining information.

11. Safeguards and privacy incidents

We maintain administrative, technical and physical safeguards appropriate to the sensitivity, volume and nature of the personal information we handle.

These measures include access restrictions, secure transmission where appropriate, staff confidentiality requirements and safeguards governing service providers.

Access is limited to personnel and service providers who require the information for authorized purposes.

No internet transmission or storage system is completely secure. We cannot guarantee absolute security.

If a privacy incident occurs, we assess it, take appropriate containment and corrective measures, and meet applicable reporting, notification and record-keeping requirements.

12. Access, correction and complaints

Subject to applicable law, you may request:

• information about our handling of your personal information;
• access to personal information under our control;
• correction of inaccurate or incomplete information;
• withdrawal of consent;
• deletion of information we no longer need or are not required to retain; and
• investigation of a privacy complaint.

Please submit requests to our Privacy Officer using the contact information below. We may require reasonable verification of your identity before releasing or changing information.

We respond within the period required by the applicable legislation. Where PIPEDA applies, access requests are generally addressed within 30 days, subject to permitted extensions.

Where access or another request is restricted by law, we explain the reason to the extent permitted.

If you are dissatisfied with our response, you may contact the Office of the Privacy Commissioner of Canada or the relevant provincial privacy regulator, including the Office of the Information and Privacy Commissioner of Alberta, as applicable.

13. Information concerning minors

Our website is primarily intended for adults seeking information about debt and insolvency.

We do not knowingly collect personal information directly from minors through general website forms or chat without appropriate authority or consent.

Limited information about dependants may be relevant to assessing household circumstances. Please provide only the information requested and avoid unnecessary identifying details about children.

If you believe a minor has submitted information inappropriately, contact our Privacy Officer. We will assess the circumstances and take appropriate action, including deletion where legally permitted.

14. Changes to this Policy

We may update this Policy to reflect changes in our practices or applicable requirements. The date above identifies the latest revision.

Where a change introduces a new purpose requiring consent, we obtain that consent before using or disclosing previously collected information for the new purpose. Posting a revised Policy does not, by itself, establish that consent.

15. Contact our Privacy Officer

For privacy questions, access or correction requests, withdrawal of consent or complaints, contact:

Privacy Officer
Day Group Inc.
6109 – 46 Street
Leduc, Alberta T9E 6T8
Telephone: 825-450-2193
Email: claims@daydebt.com